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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q25-Q30):
NEW QUESTION # 25
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it.
The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
From a business standpoint, what is the most productive way to view employee use of personal equipment for work-related tasks?
- A. Any computer or other equipment is company property whenever it is used for company business.
- B. The use of personal equipment must be reduced as it leads to inevitable security risks.
- C. The use of personal equipment is a cost-effective measure that leads to no greater security risks than are always present in a modern organization.
- D. While the company may not own the equipment, it is required to protect the business-related data on any equipment used by its employees.
Answer: D
Explanation:
This answer reflects the principle of accountability, which states that the company is responsible for ensuring that personal data is processed in compliance with applicable laws and regulations, regardless of who owns or controls the equipment that stores or processes the data. The company should establish policies and procedures for managing the use of personal equipment for work-related tasks, such as requiring encryption, authentication, remote wipe, backup and reporting of incidents. The company should also provide training and awareness to the employees on how to protect the data on their personal equipment and what are their obligations and liabilities. References: IAPP CIPM Study Guide, page 841; ISO/IEC 27002:2013, section
6.2.1
NEW QUESTION # 26
In privacy protection, what is a "covered entity"?
- A. A privacy office or team fully responsible for protecting personal information.
- B. An organization subject to the privacy provisions of HIPAA.
- C. Hidden gaps in privacy protection that may go unnoticed without expert analysis.
- D. Personal data collected by a privacy organization.
Answer: B
Explanation:
Explanation
A covered entity is an organization that is subject to the privacy provisions of the Health Insurance Portability and Accountability Act (HIPAA) of 1996. HIPAA regulates how covered entities use and disclose protected health information (PHI) of individuals. Covered entities include health plans, health care clearinghouses, and health care providers that transmit health information electronically. References: [HIPAA for Professionals],
[What is a Covered Entity?]
NEW QUESTION # 27
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments.
After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What element of the Privacy by Design (PbD) framework might the Handy Helper violate?
- A. Failure to obtain opt-in consent to marketing.
- B. Failure to integrate privacy throughout the system development life cycle.
- C. Failure to observe data localization requirements.
- D. Failure to implement the least privilege access standard.
Answer: B
Explanation:
The Handy Helper might violate the element of the Privacy by Design (PbD) framework that requires integrating privacy throughout the system development life cycle. According to the PbD framework, privacy should be embedded into the design and architecture of IT systems and business practices, not added as an afterthought1 This means that privacy should be considered at every stage of the system development life cycle, from planning to analysis to design to development to implementation to maintenance2 However, the Handy Helper seems to have been developed without involving Sanjay, the head of privacy, or conducting a privacy impact assessment (PIA) to identify and mitigate potential privacy risks3 The product also lacks a clear and transparent privacy notice that informs users about what data is collected, how it is used, where it is stored, who has access to it, and what choices they have4 These issues could expose the product to legal and reputational challenges, especially in regions with strict data protection regulations, such as Europe. References: 1: Privacy by Design - The LIFE Institute; 2: System Development Life Cycle - GeeksforGeeks; 3: [Privacy Impact Assessment (PIA) | NZ Digital government]; 4: [Privacy Notices under EU Data Protection Law | Privacy International]
NEW QUESTION # 28
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.
During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime.
Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution.
Furthermore, the off- premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is a TRUE statement about the relationship among the organizations?
- A. MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.
- B. Cloud Inc. must notify A&M LLP of a data breach immediately.
- C. Cloud Inc. should enter into a data processor agreement with A&M LLP.
- D. A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.
Answer: A
Explanation:
A true statement about the relationship among the organizations is that MessageSafe is liable if Cloud Inc.
fails to protect data from A&M LLP. This statement reflects the principle of accountability under the GDPR, which requires data controllers and processors to be responsible for complying with the GDPR and demonstrating their compliance4 As a data processor for A&M LLP, MessageSafe is liable for any damage caused by processing that infringes the GDPR or by processing that does not comply with A&M LLP's lawful instructions5 This liability extends to any sub-processors that MessageSafe engages to carry out specific processing activities on behalf of A&M LLP5 Therefore, if Cloud Inc., as a sub-processor for MessageSafe, fails to protect data from A&M LLP and causes harm to the data subjects or breaches the GDPR or A&M LLP's instructions, MessageSafe will be held liable for such failure and may have to pay compensation or face administrative fines or other sanctions6 References: 4: Article 5 GDPR | General Data Protection Regulation (GDPR); 5: Article 82 GDPR | General Data Protection Regulation (GDPR); 6: Article 83 GDPR | General Data Protection Regulation (GDPR)
NEW QUESTION # 29
Which of the following best demonstrates the effectiveness of a firm's privacy incident response process?
- A. The decrease of security breaches
- B. The decrease of notifiable breaches
- C. The increase of privacy incidents reported by users
- D. The decrease of mean time to resolve privacy incidents
Answer: D
Explanation:
The decrease of mean time to resolve privacy incidents best demonstrates the effectiveness of a firm's privacy incident response process. This metric measures how quickly and efficiently the firm can identify, contain, analyze, remediate, and report privacy incidents. A lower mean time to resolve indicates a higher level of preparedness, responsiveness, and resilience in handling privacy incidents. References: IAPP CIPM Study Guide, page 25.
NEW QUESTION # 30
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